Our commitment to You and the protection of Your data

As a Data Processor, CareMonkey is committed to partnering with customers and users to help them understand and comply with the EU General Data Protection Regulation (GDPR). The GDPR strengthens the rights individuals have regarding organisations holding personal data relating to them, and applies to any organisation that does business in the EU, including schools, academies and other educational establishments (and their supplying software companies such as CareMonkey).

Users have the additional security option to enable Two-Step Verification (also known as Two-Factor Authentication), which prevents anyone from accessing a User’s account without possessing their mobile device.

CareMonkey will always notify Users by email when account is accessed from a new device or browser.

Encryption

CareMonkey uses encryption to protect data in transit and at rest. Data in transit is protected using HTTPS, which is activated by default for all users. CareMonkey encrypts data stored at rest, without any action required from users, using one or more encryption mechanisms.

Additional Mobile Data Security

The CareMonkey App is registered on a device using your unique username and password. Second Factor code/fingerprint is then required to access data.

Data is only accessible by authorised users with that unique username and password.

All data transfer is handled over SSL secure connections. CareMonkey uses an “Extended Validation” SSL site certificate so that users can be sure they are talking to CareMonkey when accessing the data.

When the CareMonkey App is accessed on a mobile device or tablet, the data is stored in an encrypted format to give authorised users access to emergency information, even when they are offline or outside mobile range.

Data that is stored on your device automatically expires and is deleted from local storage after a set period of time, unless authorized users re-synchronise with the server.

Data that is no longer authorised is automatically deleted from local storage.

Network Protection

CareMonkey is designed with intrusion detection firewalls and actively monitors to detect intrusions into our system.

CareMonkey continuously optimises its security infrastructure, both within the application code and across our network/platform.

AWS data centers are state of the art, utilising innovative architecture and engineering approaches. AWS provides a highly reliable, scalable and secure infrastructure platform that powers hundreds of thousands of businesses in 190 countries across the world.

Data is stored on servers in that region, and will never be stored outside of that region. For citizens (data subjects) in the EU, data is stored in Ireland (Dublin).

AWS is fully compliant with applicable EU data protection laws, and the AWS Data Processing Agreement incorporates the Article 29 Working Party Model Clauses. This means that users wishing to transfer personal data from the European Economic Area (EEA) to other countries can do so knowing that their content in AWS will be given the same high level of protection it receives in the EEA.

CareMonkey backs up your data in the same region every hour.

Protecting Rights of Data Subjects

Collecting Consent

All CareMonkey Users are required consent to the Terms of Servicebefore they can create a CareMonkey Account, and enter any data into CareMonkey. CareMonkey’s Terms and Privacy Policy are explicit about what data is collected, and the purpose the data is used for.

When Data Controllers (e.g. schools, clubs or businesses) use CareMonkey to request information, Users choose to opt-in by agreeing to Share that information with each organisation.

CareMonkey will NEVER share your data to anyone without your consent.

NOTE: CareMonkey is designed for adult users to share electronic medical and consent forms with other organisations. For children (data subjects) under legal adult age, valid consent is required from a parent or guardian. Therefore children under legal age have no purpose using CareMonkey.

User Rights of Access and Access to Usage Data

CareMonkey allows Users to access all the personal data they entered on behalf of themselves, and other individuals they are responsible for (e.g their child). This includes emergency contacts, medical conditions, personalised care instructions and responses to any form requests from an Organisation.

Users can see which Organisations they have shared which information with.

Users can see what personal information CareMonkey processes on behalf of the data controller in the Privacy Policy.

Users can view pre-built reports logging every sign-in, and every registered device.

Users can transfer Profile information to other Users (e.g. transfer control of their child’s profile to another parent/guardian, or to their child once they become a legal adult).

Users can export their personal data stored in CareMonkey in an open standard electronic format (JSON). This includes ‘observed’ data such as Recent Log-ins, and Registered Devices.

Customers can export their organisation’s data in an open standard electronic format (JSON).

Data Retention

CareMonkey stores data until it is no longer necessary to provide services to the Data Subject and the Data Controller.

CareMonkey does not automatically delete information about Data Subjects because CareMonkey is fully User controlled. Users can choose to share CareMonkey Care Profiles with other users (e.g. other parents/guardians), and other organisations (e.g. another school, club).

Users can permanently delete their account at anytime.

If the User shared any eForm response with an organisation (e.g. medical form, consent form), the shared form becomes the property of that organisation (data controller), and the organisation will continue to have that copy after the User deletes their account.

CareMonkey enables the Customer (Data Controller) to archive or permanently delete data when it is no longer required. It is the responsibility of the Data Controller to know how long data is required to be kept for compliance or legal reasons. How long data is required to be kept depends on local laws and regulations, which is why CareMonkey does not automatically delete any data.

Deletion of Data (right to erasure, and the right to refuse)

Users can permanently delete their CareMonkey Account (including all profile/member information) at any time.

If a User has completed a form on behalf of the Data Controller, that eForm response becomes the property of the Data Controller. For example, if a parent completes a consent form for their child to attend an excursion, that consent form and a snapshot of the Care Profile at the time of consent is stored by CareMonkey (data processor) on behalf of the Customer (data controller).

If a User chooses to permanently delete their account, CareMonkey will make the User aware of which Organisations have stored shared information (and the Super-Admin contact details) prior to the User confirming permanent deletion, thus ensuring the User knows where to direct requests for erasure.

Data Subjects have a right to erasure, and can contact the organisation (data controller) to delete any personal data related to them under GDPR Article 17. CareMonkey provides the tools for the data controller to find that information, and permanently delete their record of User data.

Under GDPR Article 17, the data controller has a right to refuse the request to erasure of personal data if that data is required to:

To comply with legal obligations for the performance of a public interest task or exercise of official authority

When the data is necessary for the exercise or defence of legal claims

A key purposes of CareMonkey is to collect and store consent forms that are required for an organisation to deliver on their compliance and duty of care obligations. Data controllers (in particular schools) are bound by data retention guidelines set out by their local authorities. Therefore, it is the responsibility of the Data Controller to know their regulations and be certain data is not required for compliance or future legal cases before permanently deleting any data.

If the Data Controller has no grounds to refuse a Data Subjects request to erasure, they must comply without undue delay or at most within a month of the request.

CareMonkey has a risk management program to ensure appropriate measure are taken to protect personal information. This procedure applies to all systems, employees, consultants, temporaries and other workers at CareMonkey.

CareMonkey supports Data Controllers in their mandatory requirement to conduct PIAs to ensure they are in compliance as projects progress.

Data Breach Notifications

In the event of a suspected data breach, CareMonkey has a Critical Incident Response Team (which includes our Data Protection Officer, Developers, and Senior Management), and a Data Breach Policyand Incident Response Plan that is reviewed annually.

In the event of a data breach, CareMonkey will notify the Data Controller without undue delay after becoming aware.

Individual Data Subjects will be notified if adverse impact is determined.

CareMonkey notify the appropriate EU authority within 72 hours after having become aware of the data breach.

Stay Updated

Fulfilling our privacy and data security commitments is important to us. So we’re glad to help you prepare for the changes the GDPR brings. This page will be revised to reflect GDPR-related information as it becomes available. If you have any questions about how CareMonkey can help you with compliance, we hope you’ll reach out to us on security@caremonkey.com.